| 19604600 | Sections 90 & 9(1)(i) Article 13(3A) Double taxation relief - Agreement between India and Mauritius -- Assessees were private companies incorporated in Mauritius, holding a Global Business Licence and va......
SC -- 15 Jan 2026
The Authority For Advance Rulings (Income Tax) & Ors. v. Tiger Global International II, IV, III Holdings
Civil Appeal No. 262 of 2026 [Arising out of SLP (C) No. 2640 of 2025], with Civil Appeal No. 263 of 2026 [Arising out of SLP (C) No. 2565 of 2026] [Arising out of SLP (C) Diary No. 1260 of 2025], with Civil Appeal No. 264 of 2026 [Arising out of SL
2026 TaxPub(DT) 458 (SC)
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| 19240700 | Section 9(1)(vi) Income deemed to accrue or arise in India - Under section 9(1)(vi) - Royalty - Rei -- AO held that reimbursement of lease line charges received by assessee would come within term |proces......
Del-HC -- 06 Oct 2025
CIT v. Expeditors International of Washington Inc. Appeal Dismissed
ITA No. 491/2025
2025 TaxPub(DT) 7299 (Del-HC)
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| 18979800 | Section 90 Article 12 Double taxation relief - Agreement between India and USA - Fees for Technic -- Assessee-LLP based at USA, had an arrangement for seconding employees to its Indian member firms, re......
Del-Trib -- 31 Jul 2025
Ernst & Young U.S. LLP v. ACIT Assessee Appeal Allowed
ITA No. 1254/Del/2025, ITA No. 1243/Del/2025
2025 TaxPub(DT) 5781 (Del-Trib)
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| 18997000 | Section 92C Transfer Pricing - Determination of ALP - Alternate adjustment proposed by TPO - -- TPO proposed an alternate adjustment for the Software Development services segment. This adjustment ......
Pune-Trib -- 18 Jul 2025
Spectraforce Technologies (India) (P) Ltd. v. ACIT Assessee Appeal Partly Allowed
ITA No. 2853/PUN/2024
2025 TaxPub(DT) 5920 (Pune-Trib)
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| 18979300 | Section 9(1)(vii) Income deemed to accrue or arise in India - Under section 9(1)(vii) - Fees for -- Assessee, a foreign company based at UK, received payments totaling Rs. 10,06,66,731 from HSBC Elect......
Mum-Trib -- 16 Jul 2025
Dy. CIT v. HSBC Bank PLC Revenue Appeal Dismissed
ITA No. 1538/MUM/2025
2025 TaxPub(DT) 5776 (Mum-Trib)
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| 18980600 | Section 92C Transfer Pricing - Determination of ALP - Interest paid to AE - -- TPO made certain adjustment with respect to interest paid by assessee-company to its AE on ECB loans......
Bang-Trib -- 07 Jul 2025
Gleason Works (India) (P) Ltd. v. CIT Assessee Appeal Allowed
IT(TP) No. 2140/Bang/2024
2025 TaxPub(DT) 5789 (Bang-Trib)
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| 18836000 | Section 6(3) Articles 4(1) Article 13(4) Income deemed to accrue or arise in India - Determination o -- Held: From the dictionary meanings of the word as given in Webster Dictionary and Blac......
Del-Trib -- 30 Jun 2025
Essar Com Ltd. v. ACIT In assessees favour.
ITA Nos. 339 & 340/Del/2022
2025 TaxPub(DT) 4938 (Del-Trib)
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| 18880200 | Section 32(1)(ii) Depreciation - Allowability of - On Brand Value (Intangible Asset) - -- Assessee had acquired a business on a going concern basis, and the purchase consideration included a......
Chen-Trib -- 23 Jun 2025
ACIT v. Carborundum Universal Ltd. Revenue Appeal Dismissed
ITA Nos. 139, 140 & 117/CHNY/2025
2025 TaxPub(DT) 5195 (Chen-Trib)
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